- 6 - performing covered services. Sec. 1.448-1T(e)(4)(i), Temporary Income Tax Regs., supra. In calculating the amount of employee time spent performing covered services, administrative and support services incident to covered services are treated as covered services. Id. Section 448(d)(2), the regulations thereunder, and court opinions generally do not define accounting services.2 However, in section 1.448-1T(e)(5)(vii), Example 1(i), Temporary Income Tax Regs., 52 Fed. Reg. 22770 (June 16, 1987), the preparation of tax returns and audit and financial statements are treated as accounting services: X, a corporation, is engaged in the business of providing accounting services to its clients. These services consist of the preparation of audit and financial statements and the preparation of tax returns. For purposes of section 448, such services consist of the performance of services in the field of accounting. * * * Petitioner concedes that, if tax return preparation and bookkeeping services constitute accounting services, by virtue of Rodgers’ and Rodgers’ estate’s ownership of petitioner’s stock, the above ownership test has been satisfied. 2 In Ron Lykins, Inc. v. Commissioner, T.C. Memo. 2006-35, the parties did not dispute that tax return preparation services constituted accounting services.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011